EU packaging rulesSign inYour listing

Situation

A business based outside the EU that ships to customers inside it

The situation

A business registered outside the EU sends packaged goods directly to people in EU countries, rather than selling to a distributor who resells them.

What appears to apply

  • When a business counts as a producer, and in which country

    Applies now

    Producer is the word the rules use for whoever first puts packaging onto a country's market. It is worked out country by country, so one business can be a producer in several countries at once. There are five ways to become one, and the first four split by what is being made available rather than only by where. Two cover a business in its own country. One is for packaging on its own: the outer boxes and wrapping goods travel in, the cups and bags filled at a counter, the packaging used in farming and fishing. The other is for goods inside any other packaging. Two more cover the same pair sent to another EU country, but only where the goods go directly to the people who will use them. The fifth catches a business that unpacks goods without being the one who uses them, unless somebody earlier in the chain already counts as the producer.

    Source: Regulation (EU) 2025/40, Art. 3(1), point (15) — read from this source on

    The two about another country decide whether a representative is needed there, and both turn on selling directly to end users — sending a pallet to a wholesaler abroad is not the same thing. The fifth, about unpacking, is the one most often missed.

  • Selling to another EU country and needing a representative there

    Applies now

    A business that sends packaged goods straight to customers in another EU country has to appoint someone based in that country to handle its packaging duties there. The rules call this person an authorised representative for extended producer responsibility. It has to be done in writing, and separately for each country. For businesses based outside the EU the picture is different: each country decides for itself whether to require one.

    Source: Regulation (EU) 2025/40, Art. 45(3) — read from this source on

    The rules use the same phrase, authorised representative, for a different job to do with product paperwork. Same words, different role.

    National divergences recorded for this rule

    • Austria requires a business with no seat or branch in Austria that sells packaged goods at a distance to private customers there to appoint an Austrian representative. A business seated in another Member State that supplies only other businesses may appoint one, but does not have to. Austria also asks for more than a signed letter. The appointment is made by a “beglaubigte Vollmacht” — a power of attorney whose signature has been authenticated. It has to be in German or English, list which collection and treatment categories it covers, and record that the representative agrees to take on the duties. The representative also needs an Austrian address for post.

      Source: Unternehmensserviceportal (USP), Republic of Austria — read from this source on

    • In Germany an authorised representative takes on every extended producer responsibility duty except one: entry in the LUCID packaging register. Registering, and later changing those registration details, stays a duty of the business itself and cannot be handed over.

      Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on

    • A business based outside Germany that sells empty packaging or packaged goods straight to end users in Germany, with no branch there, appoints an authorised representative. That representative is entered in the LUCID register before anything is first made available on the German market. The German rules set out no exemption.

      Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on

    • Germany sets three conditions on who can act as an authorised representative. The representative needs a registered office or a branch in Germany, the appointment is made by a written agreement in German, and the representative holds their own separate login for the LUCID packaging register.

      Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on

Countries with extra requirements of their own

Only countries that have been checked appear here. A country's absence means nobody has looked at it yet, not that it asks for nothing extra.

Find someone who acts as a representativeThis site lists people and companies who say they act as a representative, organised by the country they act in. Nobody here is checked, rated or ranked — each listing is what that person wrote about themselves, and the conversation happens directly between the two parties.

Other situations are set out under common situations.